Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 1 of 48
`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 1 of 48
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`EXHIBIT 2
`EXHIBIT 2
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 2 of 48
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`CHART A
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`Twitter Inc. (“Twitter”) manufacturers, supports, and operates a messaging and communication platform (the “Twitter
`Network”). The Twitter Network enables a wireless device to establish communications with a destination node as described in U.S.
`Patent No. 10,880,721 (hereinafter the ‘721 Patent) and set forth in the asserted claims.
`
`The Twitter Network includes the microblogging and social networking service Twitter, which is a cross-platform centralized
`messaging and communication service owned by Twitter, Inc. The Twitter Network allows smartphone and desktop users to send text
`messages, make voice and video communications, and share images, documents, user locations, and other content. See
`https://apps.apple.com/us/app/twitter/id333903271.
`
`In the Twitter Network, users of the desktop computers, laptops, tablets, smartphones, and mobile devices can send messages
`including text, images, video and audio to others using Twitter client software applications developed by Twitter for supported devices
`to communicate with a Twitter server infrastructure owned and operated by Twitter. The Twitter client software applications running
`on most supported devices includes Twitter direct messaging, which is a communications feature incorporating techniques described
`in the ‘721 Patent. Additionally, in the Twitter Network, the Twitter server infrastructure includes one or more communication
`networks, one or more servers, one or more services, and/or one or more other resources associated with the Twitter server
`infrastructure and using Twitter server software applications developed by Twitter to implement handling, routing, and delivery of
`non-real time (e.g., messages) and real time (e.g., voice and video) communication to and from the supported devices using the
`Twitter client software applications. The Twitter server software applications running on servers owned and operated by Twitter
`includes the direct messaging feature incorporating techniques described in ‘721 Patent.
`
`Chart A applies independent claim 130 of the ‘721 Patent to the Twitter Network.
`
`Chart A demonstrations that in the Twitter Network, the Twitter server infrastructure produces an access code based on a
`location identifier identifying a geographical location of the wireless device and which is used by a wireless device to establish
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 3 of 48
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`CHART A
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`communications with a destination node as described in the ‘721 Patent and defined in the asserted claims, literally and/or using the
`doctrine of equivalents. In the Twitter Network, for example, the Twitter server infrastructure produces an access code comprising one
`or more portions and/or a combination of information. In the Twitter Network, for example, the Twitter server infrastructure produces
`an access code comprising information identifying one or more Internet Protocol (IP) network addresses associated with one or more
`Twitter messaging servers in the Twitter server infrastructure and/or direct message session information obtained from one or more
`Twitter messaging servers in the Twitter server infrastructure. The IP network addresses and/or the direct message session
`information, for example, identifies a communications channel on a gateway (e.g., one or more Twitter messaging servers in the
`Twitter server infrastructure) through which communications between the wireless device and the destination node can be conducted.
`In the Twitter Network, for example, the Twitter server infrastructure enables communications from the wireless device to the
`destination node to be initiated using the access code as described in the ‘721 Patent and defined in the asserted claims, literally and/or
`using the doctrine of equivalents.
`
`Chart A uses one scenario of infringement as an example to demonstrate how elements of the asserted claims read on the use
`of a domain name system (DNS) associated with the Twitter Network to produce one or more portions and/or combinations of
`information representing an access code that is based on a location identifier identifying a geographical location of a wireless
`apparatus and that identifies one or more Internet Protocol (IP) network addresses associated with one or more Twitter messaging
`server in the Twitter server infrastructure and/or direct message session information obtained via the one or more Twitter messaging
`servers to enable mobile telephone roaming as described in the ‘721 Patent and defined in the asserted claims, literally and/or using
`the doctrine of equivalents. The scenario set forth in Chart A using DNS is one example made without limitation to one or more
`additional scenarios of infringement, which may be described in other charts using at least some of the components and/or processes
`associated with the Twitter Network already identified in Chart A, further demonstrating how the asserted claims read, literally and/or
`using the doctrine of equivalents, on the Twitter Network.
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 4 of 48
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`CHART A
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 4 of 48
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`CHART A
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 5 of 48
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`CHART A
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`130. [130p] A method of
`operating an apparatus
`for enabling a wireless
`device to establish
`communications with a
`destination node, the
`method comprising:
`
`U.S. Patent No. 10,880,721
`The Twitter Network performs a method of operating an apparatus for enabling a wireless device
`to establish communications with a destination node.
`
`In the Twitter Network, for example, establishing communications between a wireless device and
`a destination node of a communications network is performed when the Twitter server
`infrastructure owned and operated by Twitter produces an access code based on a geographic
`location associated with the wireless device and which is used by the wireless device to initiate
`communications from the wireless device to the destination node as described in the ‘721 Patent
`and defined in claim 130, literally and/or using the doctrine of equivalents.
`
`In the Twitter Network, for example, a Twitter subscriber’s mobile telephone (i.e., a wireless
`device) initiates a process for sending a Twitter direct message within a user interface associated
`with a Twitter client software application. The Twitter subscriber’s mobile telephone uses the
`Twitter client software application to establish communication with the Twitter server
`infrastructure by requesting access to the Twitter server infrastructure. In response to the Twitter
`client software application requesting access, the Twitter server infrastructure produces an IP
`network address (i.e., an access code) of one or more Twitter messaging servers based on a
`geographic location directly and/or indirectly associated with the Twitter subscriber’s mobile
`telephone and which is used by the Twitter subscriber’s mobile telephone to initiate
`communications from the Twitter subscriber’s mobile telephone to the destination node using the
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 6 of 48
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`CHART A
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`Twitter messaging servers as described in the ‘721 Patent and defined in claim 130, literally
`and/or using the doctrine of equivalents. The destination node may be embodied as one or more
`Twitter messaging servers behind one or more Twitter messaging server load balancers, a
`participant to the communication, a group of participants to the communication, and/or as a
`device associated with a participant to the communication.
`
`As discussed further below, the Twitter server infrastructure includes:
` One or more Twitter authoritative domain name system (DNS) servers associated with the
`Twitter server infrastructure that provide a naming system for one or more communication
`networks, one or more servers, one or more services, and/or other resources associated
`with the Twitter server infrastructure and using Twitter server software applications
`developed by Twitter to implement initialization, routing, and delivery of non-real time
`(e.g., messages) and real time (e.g., voice and video) communication to and from
`supported devices using the Twitter client software applications. The Twitter authoritative
`DNS servers associate domain names used by the Twitter client software application with
`various information (such as IP network addresses) that provide access to the
`communication networks, servers, services, and/or other resources associated with the
`Twitter server infrastructure.
` One or more Twitter messaging servers associated with the Twitter server infrastructure
`that provide handling, routing, and delivery of non-real time (e.g., messages) and real time
`(e.g., voice and video) communication to and from supported devices using the Twitter
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 7 of 48
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`CHART A
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`client software applications. The Twitter messaging servers include the Twitter server
`software applications developed by Twitter provide access to exchange messages
`(including chats, group chats, images, videos, voice messages and files) around the world.
`
`
`The Twitter Network performs this limitation of receiving from the wireless device a request
`message. In the Twitter Network, for example, the Twitter authoritative DNS server and/or the
`Twitter messaging servers associated with the Twitter server infrastructure perform this limitation
`using the Twitter server software application to provide handling, routing, and delivery of non-
`real time (e.g., messages) and real time (e.g., voice and video) communication to and from
`supported devices using the Twitter client software applications.
`
`In the Twitter Network, for example, the Twitter subscriber’s mobile telephone uses the Twitter
`client software application to communicate (or cause to be communicated) one or more parts,
`portions, and/or combinations of information associated with a request message. In the Twitter
`Network, for example, the Twitter server infrastructure uses the Twitter server software
`application to obtain (or cause to be obtained) these parts, portions, and/or combinations of
`information associated with the request message using one or more communications and/or a
`combination of communications associated with the Twitter subscriber’s mobile telephone. In the
`Twitter Network, for example, the Twitter server infrastructure uses the Twitter server software
`application to obtain (or cause to be obtained) the parts, portions, and/or combinations of
`information associated with the request message using the communications and/or combination of
`
`
`
`[130a-1] receiving from
`the wireless device a
`request message
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 8 of 48
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`CHART A
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`communications associated with the Twitter subscriber’s mobile telephone with one or more
`access servers and/or a combination of access servers associated with the Twitter server
`infrastructure:
`
`In one or more communications and/or a combination of communications associated with
`receiving from the wireless device a request message, the Twitter server infrastructure
`uses the Twitter server software application to obtain (or cause to be obtained) a first part
`of the request message associated with the Twitter subscriber’s mobile telephone with one
`or more of the Twitter authoritative DNS servers. In the Twitter Network, for example,
`the Twitter authoritative DNS servers provide access to the communication networks, the
`servers, the services, and/or the other resources associated with the Twitter server
`infrastructure. In the Twitter Network, for example, the Twitter authoritative DNS servers
`obtain (or cause to be obtained) the communications and/or combination of
`communications associated with the Twitter subscriber’s mobile telephone as information
`requesting the Twitter authoritative DNS servers to provide access to the communication
`networks, the servers, the services, and/or the other resources associated with the Twitter
`server infrastructure to exchange a message or setup and initiate a call. In the Twitter
`Network, for example, the information requesting the Twitter authoritative DNS servers to
`provide access includes and/or is communicated using one or more packets produced (or
`caused to be produced) by the Twitter subscriber’s mobile telephone. In the Twitter
`Network, for example, the packets communicated from (or caused to be communicate by)
`the Twitter subscriber’s mobile telephone with the Twitter authoritative DNS servers
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 9 of 48
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`CHART A
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`comprise one or more DNS queries including the domain name “api.twitter.com” that
`query the Twitter authoritative DNS servers for one or more IP network addresses
`associated with one or more of the Twitter messaging servers. Specifically, the Twitter
`server infrastructure obtains at least one DNS query including the domain name
`“api.twitter.com” asking the Twitter authoritative DNS servers for the IP network
`addresses associated with the Twitter messaging servers geographically situated relative to
`the Twitter subscriber’s mobile telephone based on the location of the Twitter subscriber’s
`mobile telephone.
`
`
`
`
`
`See e.g., https://developer.twitter.com/en/docs/twitter-api/direct-
`messages/lookup/migrate/standard-to-twitter-api-v2.
`In one or more communications and/or a combination of communications associated with
`receiving from the wireless device a request message, the Twitter server infrastructure
`uses the Twitter server software application to obtain (or cause to be obtained) a second
`part of the request message associated with the Twitter subscriber’s mobile telephone with
`one or more of the Twitter messaging servers. In the Twitter Network, for example, the
`Twitter messaging servers provide access to the Twitter server software applications
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 10 of 48
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`CHART A
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`developed by Twitter to exchange messages (including chats, group chats, images, videos,
`voice messages and files). In the Twitter Network, for example, the Twitter messaging
`servers obtain the communications and/or combination of communications associated
`with the Twitter subscriber’s mobile telephone as information requesting the Twitter
`messaging servers to provide access to exchange a message or setup and initiate a call. In
`the Twitter Network, for example, the information requesting the Twitter messaging
`servers to provide access includes and/or is communicated using one or more packets
`produced (or caused to be produced) by the Twitter subscriber’s mobile telephone. In the
`Twitter Network, for example, the packets communicated from (or caused to be
`communicate by) the Twitter subscriber’s mobile telephone with the Twitter messaging
`servers comprise information asking one or more geographically situated Twitter
`messaging servers to establish a message session. Specifically, the Twitter server
`infrastructure obtains at least one API request including the domain name
`“api.twitter.com” and the Twitter messaging URI identifying an endpoint root path of
`“/1.1/direct_message” or “/2/dm_converstations” asking the Twitter messaging servers
`geographically situated relative to the Twitter subscriber’s mobile telephone to establish a
`direct message session.
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 11 of 48
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`CHART A
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`
`
`See e.g., https://developer.twitter.com/en/docs/twitter-api/direct-
`messages/lookup/migrate/standard-to-twitter-api-v2.
`
`
`The Twitter Network receives from the wireless device a request message including a destination
`node identifier associated with the destination node. In the Twitter Network, for example, the
`Twitter authoritative DNS server and/or the Twitter messaging servers associated with the Twitter
`server infrastructure perform this limitation using the Twitter server software application to
`provide handling, routing, and delivery of non-real time (e.g., messages) and real time (e.g., voice
`and video) communication to and from supported devices using the Twitter client software
`applications.
`
`In the Twitter Network, for example, the Twitter server infrastructure uses the Twitter server
`software application to receive (or cause to be received) the parts, portions, and/or combinations
`
`
`
`[130a-2] including a
`destination node
`identifier associated with
`the destination node and
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 12 of 48
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`CHART A
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`of information associated with the request message identified as set forth in element [130a-1]. In
`the Twitter Network, for example, the Twitter server infrastructure uses the Twitter server
`software application to obtain (or cause to be obtained) the parts, portions, and/or combinations of
`information associated with the request message using the communications and/or combination of
`communications associated with the Twitter subscriber’s mobile telephone with one or more of
`the Twitter messaging servers associated with the Twitter server infrastructure:
`
`In one or more communications and/or a combination of communications associated with
`receiving from the wireless device a request message, the Twitter server infrastructure uses the
`Twitter server software application to obtain (or cause to be obtained) the communications and/or
`combination of communications associated with the Twitter subscriber’s mobile telephone with
`one or more of the Twitter messaging servers. Specifically, the Twitter server infrastructure
`obtains at least one API request including the domain name “api.twitter.com” and the Twitter
`messaging URI identifying an endpoint root path of “/1.1/direct_message” or
`“/2/dm_converstations” asking the Twitter messaging servers geographically situated relative to
`the Twitter subscriber’s mobile telephone to establish a direct message session.
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 13 of 48
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`CHART A
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`See e.g., https://developer.twitter.com/en/docs/twitter-api/direct-
`messages/lookup/migrate/standard-to-twitter-api-v2.
`
`The Twitter server infrastructure obtains the API request identifying the domain name
`“api.twitter.com” and the Twitter messaging URI identifying an endpoint root path of
`
`
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 14 of 48
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`CHART A
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`“/1.1/direct_message” or “/2/dm_converstations” comprising destination nodes for API events.
`
`
`See e.g., https://developer.twitter.com/en/docs/twitter-api/direct-messages/manage/introduction.
`
`The Twitter server infrastructure obtains the API request including the domain name
`“api.twitter.com” and the Twitter messaging URI identifying an endpoint root path of
`“/1.1/direct_message” or “/2/dm_converstations” as destination node identifiers of the
`geographically situated Twitter messaging servers as well as URIs with “:participant_id” and
`“:dm_converstation_id” fields as destination node identifiers of the eventual recipients of the
`Twitter direct message.
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 15 of 48
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`CHART A
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`
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`[130a-3] a location
`identifier associated with
`a geographical location
`of the wireless device,
`wherein the location
`identifier comprises a
`first Internet Protocol
`(IP) address associated
`with the wireless device;
`
`The Twitter Network receives from the wireless device a request message, where the request
`message includes a location identifier associated with a geographical location of the wireless
`device, wherein the location identifier comprises a first Internet Protocol (IP) address associated
`with the wireless device. In the Twitter Network, for example, the Twitter authoritative DNS
`server and/or the Twitter messaging servers associated with the Twitter server infrastructure
`perform this limitation using the Twitter server software application to provide handling, routing,
`and delivery of non-real time (e.g., messages) and real time (e.g., voice and video)
`communication to and from supported devices using the Twitter client software applications.
`
`In the Twitter Network, for example, the Twitter server infrastructure uses the Twitter server
`software application to receive (or cause to be received) the parts, portions, and/or combinations
`of information associated with the request message identified as set forth in element [130a-1]. In
`the Twitter Network, for example, the Twitter server infrastructure uses the Twitter server
`software application to obtain (or cause to be obtained) the parts, portions, and/or combinations of
`information associated with the request message using the communications and/or combination of
`communications associated with the Twitter subscriber’s mobile telephone with one or more of
`the Twitter authoritative DNS servers associated with the Twitter server infrastructure.
`
`In one or more communications and/or a combination of communications associated with
`receiving from the wireless device a request message, the Twitter server infrastructure uses the
`Twitter server software application to obtain (or cause to be obtained) the communications and/or
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 16 of 48
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`CHART A
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`combination of communications associated with the Twitter subscriber’s mobile telephone with
`one or more of the Twitter authoritative DNS servers. Specifically, the Twitter server
`infrastructure obtains at least one DNS query including the domain name “api.twitter.com” asking
`the Twitter authoritative DNS servers for the IP network addresses associated with the Twitter
`messaging servers geographically situated relative to the Twitter subscriber’s mobile telephone
`based on the location of the Twitter subscriber’s mobile telephone. When the Twitter subscriber’s
`mobile telephone attempts to initiate a Twitter direct message, the Twitter authoritative DNS
`servers obtain (or cause to be obtained) directly or indirectly from the Twitter subscriber’s mobile
`telephone a DNS communication in the form of a DNS query. RFC-1035 defines in § 4.1.2 a
`format for communications inside the domain protocol to carry a “question” for a DNS server to
`“answer.” The format defines a DNS question (query) as having a QNAME field holding a
`domain name that the DNS server resolves into an IP network address when the QTYPE field is
`set to “A” for IPv4 records or “AAAA” for IPv6 records. Twitter configures the Twitter
`subscriber’s mobile telephone to send or otherwise initiate DNS queries having the FQDN
`“api.twitter.com” to the Twitter authoritative DNS servers. RFC- 1035 also specifies name server
`access for communications inside the domain protocol to carry a “question” using TCP [RFC-
`793] on server port 53 as well as datagram access using UDP [RFC-768] on UDP port 53
`(decimal). TCP and UDP are communicated using internet datagrams as specified in RFC-791 for
`IPv4 and RFC-2460 for IPv6, e.g., such datagrams adhering to the defined Internet Header
`Format for IPv4 defined in §3.1 and including a source address field. The source address field
`includes a 32-bit (IPv4) or 128-bit (IPv6) address of the originator of the datagram (or packet).
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 17 of 48
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`CHART A
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`The 32-bit (IPv4) or 128-bit (IPv6) address of the originator of the datagram comprises an IP
`network address. The Twitter authoritative DNS servers use the IP network addresses of the
`originator of the DNS query datagram as a location identifier identifying a geographical location
`of the wireless apparatus.
`
`
`
`See e.g., https://blog.twitter.com/engineering/en_us/topics/infrastructure/2017/the-infrastructure-
`behind-twitter-scale.
`
`Similar to the domain name “www.twitter.com,” Twitter employs or has employed “GeoDNS to
`map Twitter subscribers to different regional IP network addresses of the Twitter messaging
`servers based on the location of “their DNS server.” The IP network addresses directly and/or
`indirectly associated with the Twitter subscriber’s mobile telephone identify a location associated
`with the Twitter subscriber’s mobile telephone, for example, as one or more absolute and relative
`locations:
` an actual geographic location associated with the Twitter subscriber’s mobile telephone,
`which is identified by an IP network address assigned to the Twitter subscriber’s mobile
`telephone by a service provider, such as a wireless carrier or Internet Service Provider
`(ISP), and which the Twitter subscriber’s mobile telephone utilizes to directly or
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 18 of 48
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`CHART A
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`indirectly cause a DNS query having the FQDN “api.twitter.com” to be sent to the Twitter
`authoritative DNS servers;
` an actual geographic location associated with the Twitter subscriber’s mobile telephone,
`which is identified by an IP network address assigned to a router by a service provider,
`such as an ISP, and it is through the router that the Twitter subscriber’s mobile telephone
`directly or indirectly causes a DNS query having the FQDN “api.twitter.com” to be sent to
`the Twitter authoritative DNS servers;
` an actual geographic location associated with the Twitter subscriber’s mobile telephone,
`which is identified by an IP network address assigned to a proxy server by a service
`provider, such as an ISP, and it is through the proxy server that the Twitter subscriber’s
`mobile telephone directly or indirectly causes a DNS query having the FQDN
`“api.twitter.com” to be sent to the Twitter authoritative DNS servers;
` an actual geographic location associated with the Twitter subscriber’s mobile telephone,
`which is identified by an IP network address assigned to a non-authoritative DNS server
`operated by a service provider, such as an ISP DNS server or a public DNS server, and it
`is through the ISP DNS server or the public DNS server that the Twitter subscriber’s
`mobile telephone directly or indirectly causes a DNS query having the FQDN
`“api.twitter.com” to be sent to the Twitter authoritative DNS servers;
` a relative location associated with the Twitter subscriber’s mobile telephone and the
`Twitter telecom infrastructure, which is identified by an IP network address assigned by a
`service provider to the Twitter subscriber’s mobile telephone, to the router through which
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 19 of 48
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`CHART A
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`the Twitter subscriber’s mobile telephone accesses the Internet, to the proxy server
`through which the Twitter subscriber’s mobile telephone accesses the Internet, or to the
`ISP/public DNS server through which the Twitter subscriber’s mobile telephone
`communicates with the Twitter authoritative DNS servers;
` a proximate location associated with the Twitter subscriber’s mobile telephone and the
`Twitter telecom infrastructure, which is identified by an IP network address assigned by a
`service provider to the Twitter subscriber’s mobile telephone, to the router through which
`the Twitter subscriber’s mobile telephone accesses the Internet, to the proxy server
`through which the Twitter subscriber’s mobile telephone accesses the Internet, or to the
`ISP/public DNS server through which the Twitter subscriber’s mobile telephone
`communicates with the Twitter authoritative DNS servers.
`
`
`The IP network address of the originator of the datagram comprises a location identifier
`identifying a geographic location. The geographic location can be an absolute or relative location.
`The geographic location can be a:
` a physical location, such as a street address, latitude/longitude, and GPS coordinates; or
` a logical or virtual location, such as a location associated with a communications network,
`an ISP, a Wireless Service Provider, or a Wireless Carrier.
`
` A
`
` primary source for IP address location data is the regional Internet registries which allocate and
`distribute IP addresses amongst organizations located in their respective service regions:
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 20 of 48
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`CHART A
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` African Network Information Centre (AfriNIC)
` American Registry for Internet Numbers (ARIN)
` Asia-Pacific Network Information Centre (APNIC)
` Latin American and Caribbean Internet Address Registry (LACNIC)
` RIPE Network Coordination Centre (RIPE NCC)
`The registries allow assignees to specify country and geographical coordinates of each assigned
`block. See e.g., https://www.arin.net/resources/guide/request/documentation/ providing an
`example of the documentation required to request an assignment of IP network addresses and
`which asks the requestor to provide the anticipated geolocation of the requested assignment. See
`also https://help.apnic.net/s/article/Geolocation.
`
`Secondary sources for IP address location data include:
` Data mining or user-submitted geographic location data:
`o Website-submitted, e.g., a weather website asking visitors for a city name to find
`their local forecast or pairing a user's IP address with the address information in
`their account profile.
`o Wi-Fi positioning system through the examination of neighborhood Wi-Fi BSSID.
`E.g., Mozilla Location Service.
`o Examination of neighborhood Bluetooth devices.
`o Pairing a user's IP address with the GPS location of a device that's using such an
`IP address.
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`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 21 of 48
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`CHART A
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` Data contributed by Internet service providers.
` Guesstimates from adjacent Class C range and/or gleaned from network hops.
` Network routing information collected to the end point of the IP address.
` Analysis of linguistic data from the device, using pretrained models that show that some
`term is frequently mentioned in a certain location.
`
`
`The Twitter authoritative DNS servers are configured to “answer” DNS queries having the FQDN
`“api.twitter.com” in the QNAME field. Twitter configures the Twitter subscriber’s mobile
`telephone to use the FQDN “api.twitter.com” to establish direct messaging with the Twitter
`Network. As discussed further below, the Twitter authoritative DNS servers “answer” DNS
`queries having the FQDN “api.twitter.com” with IP network addresses of the Twitter messaging
`servers used with direct messaging in the Twitter Network.
`
`The Twitter Network, in response to receiving the request message, produces an access code
`identifying a second Internet Protocol (IP) address associated with an IP network communication
`device through which communications between the wireless device and the destination node can
`be conducted. In the Twitter Network, for example, the Twitter authoritative DNS server and/or
`the Twitter messaging servers associated with the Twitter server infrastructure perform this
`limitation using the Twitter server software application to provide handling, routing, and delivery
`of non-real time (e.g., messages) and real time (e.g., voice and video) communication to and from
`supported devices using the Twitter client software applications.
`
`[130b-1] in response to
`receiving the request
`message, producing an
`access code identifying a
`second Internet Protocol
`(IP) address associated
`with an IP network
`communication device
`
`
`
`20
`
`
`
`

`

`Case 3:21-cv-09773-JD Document 57-2 Filed 02/09/23 Page 22 of 48
`
`
`CHART A
`
`through which
`communications between
`the wireless device and
`the destination node can
`be conducted,
`
`
`In the Twitter Network, for example, the Twitter server infrastructure uses the Twitter server
`software application to obtain (or cause to be obtained) a request message as set forth in elements
`[130a et seq]. In response to the request message, for example, in the Twitter Network, the
`Twitter server infrastructure produces a reply message using the parts, portions, and/or
`combinations of information associated with the request message communicated from (or caused
`to be communicate by) the Twitter subscriber’s mobile telephone. The Twitter server